Aragounder Muthusamy v ITO (2024)114 ITR 47 (SN)(Chennai)(Trib)

S.147: Reassessment-Capitalisation fees-Cross examination is denied-Reassessment is quashed.[S. 132, 144A]

Held, that the addition was made based on the statement of the director. Though the assessee requested a cross-examination by filing an application before the Additional Commissioner, it was denied to him, which constituted an act of omission on the part of the Assessing Officer and Additional Commissioner in violation of the principles of natural justice. Therefore, the addition made is  deleted.(AY.2008-09)

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